Fortunato J. Mendes - Page 1

                                   121 T.C. No. 19                                    


                               UNITED STATES TAX COURT                                


                         FORTUNATO J. MENDES, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16032-95.               Filed December 11, 2003.            


                    P has been continuously incarcerated since June 17,               
               1988.  For P’s 1988 taxable year, R (1) determined a tax               
               deficiency based upon amounts reported on information                  
               returns as having been paid to P during that year, (2)                 
               imposed the 10-percent additional tax under sec. 72(t)(1),             
               I.R.C., and (3) determined that P was subject to additions             
               to tax under secs. 6651(a)(1), 6653(a)(1), and 6654, I.R.C.            
               More than 2 years after R issued the notice of deficiency, P           
               filed a 1988 return in which he reported the income from the           
               1988 information returns and listed deductions and                     
               dependency exemptions, which, in total, exceeded the                   
               reported income, thereby resulting in a zero tax liability             
               for 1988.  P now denies (1) receipt of a portion of the                
               income reported on his 1988 return and (2) liability for the           
               10-percent additional tax under sec. 72(t)(1), I.R.C.  R               
               denies that P is entitled to any of the claimed deductions             
               and dependency exemptions.                                             







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